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"This portfolio revises and supersedes 944 T.M., Aliens who invest in the United States through a low-tax jurisdiction."" ... discusses the U.S. federal income tax effects of the principal kinds of portfolio investments that are made into the United States by foreign individuals, i.e., by individuals who are classified as "nonresident aliens" for federal income tax purposes and as "nonresidents not citizens of the United States" for federal transfer tax (estate, gift, and generation-skipping transfer tax) purposes. For this purpose, potential U.S. federal taxes on non-investment personal assets (such as U.S. real property and U.S.-situs tangible personal property) are also discussed."

Description:

v. (loose-leaf) ; 28 cm.

Contents:

Detailed analysis. Introduction --
Federal taxes on U.S. investments without restructuring --
Use of a foreign holding company by a non-domiciled alien to avoid estate tax --
Inheritance of foreign holding company stock by a U.S. person --
Taxation of foreign trusts where there is no foreign holding company --
Taxation of foreign trusts where there is a foreign holding company --
Use of "dynasty trusts" for U.S. transfer tax planning purposes --
Planning by aliens moving temporarily to the United States --
Planning by aliens moving permanently to the United States --
Investment in U.S. real property --
Investment in insurance products --
Table of worksheets.